GDPR
Procedos AB
YSTAD SWEDEN
+46 72 3032343
E-MAIL: INFO@PROCEDOS.COM
- Important Information and who we are
Purpose of this privacy notice
This privacy
notice aims to give you information on how we collect and processes your
personal data through your use of this website, including any data you
may provide through this website when you sign up to our newsletter.It
is important that you read this privacy notice together with any other
privacy notice or fair processing notice we may provide on specific
occasions when we are collecting or processing personal data about you
so that you are fully aware of how and why we are using your data. This
privacy notice supplements the other notices and is not intended to
override them.
Controller – who we are
The
data controller of our site (www.procedos.com) is Procedos AB Sweden.
We have appointed a data privacy manager who is responsible for
overseeing questions in relation to this privacy notice. If you have any
questions about this privacy notice, including any requests to exercise
your legal rights, please contact info@procedos.com.You have the right
to make a complaint at any time to Datainspektionen , the Swedish
supervisory authority for data protection issues
(www.datainspektionen.se/). We would, however, appreciate the chance to
deal with your concerns before you approach Datainspektionen so please
contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This
version was last updated on 29nd March 2018. It is important that the
personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.
Third-party links
This
website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may
allow third parties to collect or share data about you. We do not
control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to read
the privacy notice of every website you visit.
- The data we collect about you
Personal data, or personal information, means any information
about an individual from which that person can be identified.We may
collect, use, store and transfer different kinds of personal data about
you which we have grouped together as follows:
Identity Data
includes first name and last name.
Contact Data
includes delivery address, email address and telephone numbers.
Financial Data
includes bank account and payment card details.
Technical Data
includes
internet protocol (IP) address browser type and version, time zone
setting and location, browser plug-in types and versions, operating
system and platform and other technology on the devices you use to
access this website.
Transaction Data
includes details about payments to and from you and other details of products and services you have purchased from us.
Usage Data
includes information about how you use our website, products and services.
Marketing and Communications Data
includes
your preferences in receiving marketing from us and our third parties
and your communication preferences.We also collect and use Aggregated
Data such as statistical or demographic data for internal purposes.We do
not collect any Special Categories of Personal Data about you (this
includes details about your race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political opinions,
trade union membership, information about your health and genetic and
biometric data). Nor do we collect any information about criminal
convictions and offences.
If you fail to provide personal data
Where
we need to collect personal data by law, or under the terms of a
contract we have with you and you fail to provide that data when
requested, we may not be able to perform the contract we have or are
trying to enter into with you (for example, to provide you with an
answer to an enquiry). In this case, we may have to cancel a service you
have with us but we will notify you if this is the case at the time.
- How is your personal data collected
We use different methods to collect data from and about you including through:
Direct interactions.
You
may give us your Identity Data, Contact Data, and Financial Data by
filling in forms or by corresponding with us by phone, email, post, fax,
on our website or otherwise. This includes personal data you provide
when you:
- purchase our products;
- register a user account on our website;
- submit an enquiry;
- enter a competition, promotion or survey; or
- request our newsletter to be sent to you.
Automated technologies or interactions.
As you
interact with our website, we may automatically collect Technical Data
about your equipment, browsing actions and patterns. We collect this
personal data by using cookies, and other similar technologies.
- How we use your personal data
We will only use your personal data when the law allows us to.
Most commonly, we will use your personal data in the following
circumstances:
- where we need to perform the contract we are about to enter into or have entered into with you;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
- where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for
processing your personal data other than in relation to sending third
party direct marketing communications to you via email or text message.
You have the right to withdraw consent to marketing at any time by
contacting us.
Purposes for which we will use your personal data
We
have set out below, in a table format, a description of all the ways we
plan to use your personal data, and which of the legal bases we rely on
to do so. We have also identified what our legitimate interests are
where appropriate.Note that we may process your personal data for more
than one lawful ground depending on the specific purpose for which we
are using your data. Please contact us if you need details about the
specific legal ground we are relying on to process your personal data
where more than one ground has been set out in the table below.
Purpose / ActivityType of DataLawful basis for processing including basis of legitimate interest
To process and deliver your order including managing payments.
(a) Identity
(b) Contact
(c) Financial
(d) Marketing and Communications
(e) Transaction(a) Performance of a contract with you.
(b) Necessary for our legitimate interests. To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey(a) Identity
(b) Contact
(c) Marketing and Communications(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c)
Necessary for our legitimate interests (to keep our records updated and
to study how customers use our products/services) To enable you to
partake in a prize draw, competition or complete a survey(a) Identity
(b) Contact
(c) Usage
(d) Marketing and Communications(a) Performance of a contract with you
(b)
Necessary for our legitimate interests (to study how customers use our
products/services, to develop them and grow our business) To respond to
your enquiry submitted on the site, or via phone, email, post or
otherwise.(a) Identity
(b) Contact(a) Performance of a contract with you.
(b)
Necessary for our legitimate interests (where you have made contact
with us prior to entering into a contractual relationship with us.) To
administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance, support,
reporting and hosting of data).(a) Identity
(b) Contact
(c)
Technical(a) Necessary for our legitimate interests (for running
ourbusiness, provision of administration and IT services, network
security, to prevent fraud and in the context of a business
reorganisation or group restructuring exercise).
(b)
Necessary to comply with a legal obligation. To use data analytics to
improve our website, products/services, marketing, customer
relationships and experiences.(a) Technical
(b)
Marketing and CommunicationsNecessary for our legitimate interests (to
define types of customers for our products and services, to keep our
website updated and relevant, to develop our business and to inform our
marketing strategy). To make suggestions and recommendations to you
about services that may be of interest to you.(a) Identity
(c) Technical
(d)
Marketing and CommunicationsNecessary for our legitimate interests (to
develop our products/services and grow our business) which, if you are
an individual, will include reliance on the soft opt-in principle (in
accordance with Regulation 22 of The Privacy & Electronic
Communications (EC Directive) Regulations 2003).
Marketing
We
strive to provide you with choices regarding certain personal data
uses, particularly around marketing and advertising. We may use your
Identity, Contact, Technical and Marketing or Communications Data to
form a view on what we think you may want or need, or what may be of
interest to you. This is how we decide which services and offers may be
relevant for you (we call this marketing).You will receive marketing
communications from us if you have requested information from us and
unless you have opted out of receiving that marketing. You can ask us or
third parties to stop sending you marketing messages at any time by
contacting us at any time.
Cookies
Our
website uses so called session cookies. Session cookies are not saved
permanently on your computer. They are erased the minute you close your
web browser. By changing the settings in your browser you can choose not
to accept cookies. However, there is a risk that our web shop
facilities will not work properly. These cookie settings are changed in
various ways, depending on which kind of browser you use. For further
instructions, please consult the “Help” section for you particular
browser.
Change of Purpose
We
will only use your personal data for the purposes for which we
collected it, unless we reasonably consider that we need to use it for
another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new
purpose is compatible with the original purpose, please contact us.
- Disclosures of your personal data
We may have to share your personal data with the parties set out
below for the purposes set out in the table in paragraph 4 above:
- External Third Parties as set out in the Glossary
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your
personal data and to treat it in accordance with the law. We do not
allow our third-party service providers to use your personal data for
their own purposes and only permit them to process your personal data
for specified purposes and in accordance with our instructions.
- International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
- Data Security
We have put in place appropriate security measures to prevent your
personal data from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. In addition, we limit access to
your personal data to those employees, agents, contractors and other
third parties who have a business need to know. They will only process
your personal data on our instructions and they are subject to a duty of
confidentiality. We have put in place procedures to deal with any
suspected personal data breach and will notify you and any applicable
regulator of a breach where we are legally required to do so.
- Data Retention
We will only retain your personal data for as long as necessary to
fulfill the purposes we collected it for, including for the purposes of
satisfying any legal, accounting, or reporting requirements.To
determine the appropriate retention period for personal data, we
consider the amount, nature, and sensitivity of the personal data, the
potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, and the
applicable legal requirements.Details of retention periods for different
aspects of your personal data are available in our retention policy
which you can request from us by contacting us.
- Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please
contact us.You will not have to pay a fee to access your personal data
(or to exercise any of the other rights). However, we may charge a
reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request in
these circumstances.
What we may need from you
We
may need to request specific information from you to help us confirm
your identity and ensure your right to access your personal data (or to
exercise any of your other rights). This is a security measure to ensure
that personal data is not disclosed to any person who has no right to
receive it. We may also contact you to ask you for further information
in relation to your request to speed up our response.We try to respond
to all legitimate requests within one month. Occasionally it may take us
longer than a month if your request is particularly complex or you have
made a number of requests. In this case, we will notify you and keep
you updated.
- Glossary
LAWFUL BASIS
Legitimate Interest
means
the interest of our business in conducting and managing our business to
enable us to give you the best service/product and the best and most
secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we
process your personal data for our legitimate interests. We do not use
your personal data for activities where our interests are overridden by
the impact on you (unless we have your consent or are otherwise required
or permitted to by law). You can obtain further information about how
we assess our legitimate interests against any potential impact on you
in respect of specific activities by contacting us.
Request access
to
your personal data (commonly known as a "data subject access request").
This enables you to receive a copy of the personal data we hold about
you and to check that we are lawfully processing it.
Request correction
of
the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may
need to verify the accuracy of the new data you provide to us.
Request erasure
of
your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process
it. You also have the right to ask us to delete or remove your personal
data where you have successfully exercised your right to object to
processing (see below), where we may have processed your information
unlawfully or where we are required to erase your personal data to
comply with local law. Note, however, that we may not always be able to
comply with your request of erasure for specific legal reasons which
will be notified to you, if applicable, at the time of your request.
Object to processing
of
your personal data where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular
situation which makes you want to object to processing on this ground as
you feel it impacts on your fundamental rights and freedoms. You also
have the right to object where we are processing your personal data for
direct marketing purposes. In some cases, we may demonstrate that we
have compelling legitimate grounds to process your information which
override your rights and freedoms.
Request restriction of processing
of
your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios: (a) if you
want us to establish the data's accuracy; (b) where our use of the data
is unlawful but you do not want us to erase it; (c) where you need us to
hold the data even if we no longer require it as you need it to
establish, exercise or defend legal claims; or (d) you have objected to
our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
Request the transfer
of
your personal data to you or to a third party. We will provide to you,
or a third party you have chosen, your personal data in a structured,
commonly used, machine-readable format. Note that this right only
applies to automated information which you initially provided consent
for us to use or where we used the information to perform a contract
with you.
Withdraw consent at any time
where
we are relying on consent to process your personal data. However, this
will not affect the lawfulness of any processing carried out before you
withdraw your consent. If you withdraw your consent, we may not be able
to provide certain products or services to you. We will advise you if
this is the case at the time you withdraw your consent.